PMLA Guidelines

The main objective of AML policy of ATS is to prevent ATS from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities. The objective of this policy is also to enable ATS understand its customers and their financial dealings better, which in turn will help ATS to manage its risks prudently.

The objective of the policy is to:–

• To have a proper Customer Due Diligence (CDD) process before registering clients.

• To monitor/maintain records of all cash transactions of the value of more than Rs.10 lacs.

• To maintain records of all series of integrally connected cash transactions within one calendar month.

• To monitor and report suspicious transactions.

• To discourage and identify money laundering or terrorist financing activities.

• To take adequate and appropriate measures to follow the spirit of the PMLA

ATS shall put in place a system of periodical review of risk categorization of accounts. Such review of risk categorization of customers shall be carried out at a periodicity of not less than once in six months. Client will be categorized as High, Medium and Low risk customer as per their risk appetite and their current profile as mentioned in Know your client form (KYC). The same will be reviewed at regular intervals as per PMLA Policy of ATS. Exposure to client may also be governed by customer profiling mentioned above as well as clients financial income made available to ATS from time to time.

Client needs to furnish their income details on yearly basis. Regular communications by means of SMS, Email are sent to clients at various intervals requesting them to update their latest financial and KYC details available with us.

Following documents will be accepted as income proof:

• Copy of ITR Acknowledgement

• Copy of Annual Accounts

• To maintain records of all series of integrally connected cash transactions within one calendar month.

• Copy of Form 16 in case of salary income

• Net worth certificate

• Salary Slip

• Bank account statement for last 6 months

• Copy of demat account Holding statement.

• Any other relevant documents substantiating ownership of assets.

If there is a major disparity between financial details and trading volumes, client will be asked to furnish suitable explanation and based on the same further trading limits will be sanctioned.

ATS may withhold the payout of client and suspend his trading account due to any internal surveillance (if client indulges into manipulative trade practice) / regulatory orders (debarring orders) / etc.) The Suspicious Transaction Report (STR) shall be furnished within 7 days of arriving at a conclusion that any transaction, whether cash or non-cash, or a series of transactions integrally connected are of suspicious nature. Systems shall be put in place for identifying transactions likely to be market manipulation, and which appears to be insider trading and also any transaction which seems to have no bona fide intention.

Policy on Delayed Payment Charges and Penalty

Clients will be liable to pay delayed/late payment charges for not making payment of their payin/margin obligation on time as per the exchange requirement/schedule at the rate of 24% pa. All clients are advised to make the payment before the pay-in time on the settlement date. It is also ensured that no position is allowed to be carried forward beyond the fifth trading day from the date of payin to meet the exchange regulations.

ATS may also impose fines/Penalties for any orders/trades/nonpayment of required margins, dishonor of cheques, cash deposit and other actions of the client which are contrary to the exchange rules or any other law in force, in such rates and in such form as it may deem fit. Further where ATS has to pay any fine or bear any punishment from any authority in connection with/as a consequence of/ in relation to any of the orders/trades/actions of the client, the same shall be borne by the client.

Delayed charges are also collected for margin shortage in derivative segments. ATS deploys its own funds for meeting margin requirement of its client at the Exchange against the stock collateral maintained by the client; the Charges on FO position are levied to the extent of shortfall in fund requirement.

Currently ATS charges late payment fees only for shortage in SPAN margin if any, and shortage in exposure margin is not charged in NSE FO segment; and in other segments exchange stipulated margin is considered in full for arriving at margin shortage amount. ATS collects late charges at a flat rate of Rs.100/- if shortage in Margin is less than Rs.1,00,000/- and less than 10% of Total Margin Requirement and Rs 500 for margin shortage of Rs 100,000 to Rs. 10,00,000/ or where shortage is more than 10% of total margin required and Rs.1000 if margin shortage is more than Rs.10,00,000.

Deposit of cash for margin money is strictly prohibited by exchanges and any cash deposits made to ATS bank accounts will be refunded back to Client’s Registered Bank Account after deducting a fine of Rs.500/-

Auction Procedure for Non Delivery of Shares and Internal Netting of Trades

Exchanges follow a T+2 rolling settlement cycle in cash segment. In case of short deliveries on the T+2 day in the normal segment, exchange conducts a buy– in auction on the T+2 day itself and the settlement for the same is completed on the T+3 day. Auction settlement is at the price determined by the exchange, which normally falls within a range of 20% of the previous day close; and the same is debited to the defaulting client ledger. Also bad/short delivery charges and processing fees levied by exchange will be debited to client.

Additionally ATS charges Rs.100 per scrip from the defaulting clients as fine for non-delivery of securities on time and leading to auction.

Internal Netting of Trades

As per the Exchange Settlement Norms the Pay in Obligation for securities are netted at member level and only net obligation is paid in to the exchange. It could be possible that within the clients of ATS, there could be opposite positions in the same scrips, which then, necessitates the internal adjustment/netting. In case a seller client fails to deliver which was to be paid out for the account of another of our clients, such a situation necessitates the Internal Auction. The settlement currently followed is as below:

Auction price of the scrip informed by the NSE for that settlement number or If Auction Price is not available in NSE for a scrip, for that settlement, highest price of the scrip prevailing in the NSE from the first day of the relevant trading period till the day of closing out on the auction day whichever is higher is considered. Generally, the auction day is considered to be T+3 day i.e. the day next to the official settlement day. The seller client will be debited with this settlement prince and the same price will be credited to the buyer client. Additionally ATS charges Rs.100/ per scrip from the defaulting clients as fine for non-delivery of securities on time and leading to auction.

Policy for Quarterly/Monthly Settlement

ATS takes the preference of settlement of clients’ at the time of account opening through the Account Opening Form. While settling the accounts, ATS may retain the requisite securities/funds towards such obligations and may also retain the funds expected to be required to meet margin obligations for next 5 trading days, calculated in the manner specified by the exchanges.

• In respect of derivative market transactions, apart from margin liability as on the date of settlement, additional margins (maximum up-to 125% of margin requirement on the day of settlement) to take care of any margin obligation arising in next 5 days may be retained.

• In respect of capital market transactions, entire pay-in obligation of funds & securities due from clients as on date of settlement may be retained. Further, in the capital market segment, for next day‟s business, member may retain funds/securities/margin to the extent of value of transactions executed on the day of such settlement in the capital market only.

• In case of settling the accounts of regular trading clients (active clients), the Member may retain an amount of up to Rs 10,000/- (net amount across segment and across stock exchanges), only after taking written consent of the client.

• The above threshold limit on retention of amount shall not be applicable in case of clients who have not traded even once during the last one month/quarter, as the case may be; i.e settlement shall be done as per the aforesaid SEBI circular, in such cases.

ATS provides the platform to buy mutual funds for clients who invest money and wait for favorable market timing can buy liquid mutual funds to ensure the exchange compliance of settlement of accounts.

ATS sends a statement of Accounts to its clients along with the settlement of funds and also a Retention statement in case the funds are retained, explaining the utilization of funds to the clients’ registered mail id.

Issuance of contract notes

ATS issues contract notes to its clients within 24 hours of the trade taking place. ATS offers the issuance of Electronic Contract Note to clients who opt for the same and it is also available to be viewed on their respective back-office Login. Along with the Contract Note, the client shall also be furnished with a copy of the daily margin status. Also trade confirmation SMS is sent to client immediately after the trade execution.

ATS will issue the contract note, margin statement and trade SMS to the mail IDs and mobile numbers mentioned in the Client registration Form. So kindly ensure that the correct mail IDs and mobile numbers are mentioned and submitted in the KYC form.

The clients will be responsible to check the digital documents including Electronic Contract Notes and bring the discrepancies if any to our notice within stipulated time of such issuance of contract notes. Non-verification or not accessing the documents on regular basis shall not be a reason for disputing the documents at any time. It will be the responsibility of client to ensure that any change in mail id is informed to ATS urgently.

Investor Grievance Resolution

ATS has a Customer Support Department to help customers resolve their doubts and grievances if any. Clients can raise their grievances through mail or phone or through our grievance section in website. Also the contact detail of Compliance Officer of ATS is published in KYCs and Contract Notes to get a clarification on their grievances and statements.

Additionally the contact details of Investor Service Cell of Exchanges are published in our KYC. Investors who are not satisfied with the response to their grievances received from ATS, can lodge their grievances with the Stock Exchanges or Depositories. Also clients can raise a complaint through SEBI Complaints Redress System (SCORES) platform. On registering the complaint, exchange calls both parties to discuss and resolve the grievances. All complaints which do not get resolved within fifteen days from the date of lodging the complaints with Exchange or cases where parties are aggrieved by the resolution worked out would be referred to Investor Grievance Resolution Panel (IGRP).

When one of the parties feels that the complaint has not been resolved satisfactorily either by the other party or through the complaint resolution process of the Exchange, the parties may choose the route of arbitration. Arbitration is a quasi-judicial process of settlement of disputes between Trading Member, investor, clearing member, sub-brokers etc. Arbitration aims at quicker legal resolution for the disputes.

If either of the parties is aggrieved by the award, the aggrieved party may approach the Exchange with an application in the prescribed format for appeal before the appellate arbitrators, along with applicable deposit, within a period of 30 days from the date of receipt of the arbitral award or the aggrieved party can challenge the award u/s 34 of Arbitration and Conciliation Act, 1996 in the court nearest to the address provided by constituent in the KYC form or as per the change in address communicated thereafter by the constituent to the trading member.

Call and Trade Service Desk and Customer Support Team

ATS offers internet and mobile trading platform to its clients wherein with the help of unique User id and password issued to them, clients can login and trade. ATS has a dedicated team at its Bangalore office, to support clients in their trading and provide clarifications on their queries. Our Support team can be reached on mail support@adityatrading.com or through phone and WhatsApp.

We also provide a call desk facility in the regional offices across the county, where in clients can call and ask our executives to place the orders which will be done after verification of the identity of the client. Also all calls made to our trade desk are recorded and saved for future records. Our Customer Support also helps you in Online Fund Transfers, authorization of entry for the funds transferred, to avoid any delay in getting the Margin Limit. Those clients who are not able to raise Fund withdrawal Request through their online Login can contact our customer support to initiate the withdrawal request.